​​6.1.6  Use of Peer-to-Peer Payment Services such as Venmo, Zelle, PayPal and others

​Peer-to-peer payment services such as Venmo, Zelle, PayPal and others may only be used to collect funds, such as donations. They may never be used to send money.  This section outlines the procedures and legal compliance requirements for accepting donations through peer-to-peer payment services.  These guidelines apply to all employees and individuals who serve in ministry in the Archdiocese of Los Angeles.

 Account Setup

• The pastor, principal or person in charge and the business manager/finance team are responsible for managing a location's peer-to-peer account and ensuring accurate record-keeping.
• The parish, school or other archdiocesan location must have an official account (such as Venmo and/or Zelle) registered under the location's name.  In most cases, it should be a business account, but in some cases such as Venmo, a charity profile is available and encouraged.  Archdiocesan locations should never use an individual's personal Venmo, Zelle, PayPal or other peer-to-peer account to receive donations.
• A parish, school or other archdiocese account may only be associated with an official bank account of the location, using the location's tax ID.  No personal bank accounts or social security numbers may be used.
• The user ID and account display name for the Venmo, Zelle or other peer-to-peer account should include the location's name so it is easily identifiable.  Do not use a pseudo-name.  A photograph of the location or a school logo may be included as an identifier.
• The pastor, principal or other person-in-charge must be an administrator on the account.  A business manager or other person who handles finances for the location should also be an administrator on the account. 
• It is important to connect the account to an official email address and phone number for the location that is used for this purpose.  An individual's personal email address may never be used on the account.  If a mobile phone number is used on the account, it must be an Archdiocesan-issued cell phone.
• Verify that all account information is accurate and secure​
• Privacy settings must be set to “Private" so that each transaction is visible only to the individual sender and the recipient location.
• Enable Multi-factor Authentication for the account.
• For security purposes, do not connect Zelle to the parish, school or other location's main checking account.  A separate bank account using the location's Tax ID number should be set up for the sole purpose of receiving Zelle payments.  This separate account should be at the same bank location that is used for the main checking account and it should be linked to the main checking account so that funds can be transferred from the Zelle account into the main checking account.  Funds should never be transferred from the main checking account into the Zelle account.
• For Venmo accounts, a charity or a business profile may be used, but a charity profile is preferred.  The Venmo account may only be associated with an official location checking account with the location's tax ID number.  Establish a regular schedule for transferring funds from the Venmo account into the parish, school or other location's main checking account.  Funds should never be transferred from the main checking account into the Venmo account.

• Direct donors to the official Venmo or Zelle account details using the ID associated with the account.  Encourage donors to include their name and contact information in the memo section of their Venmo or Zelle donation so that a receipt can be provided.  Parishioners should be encouraged to include their envelope number as well.  A receipt may not be available if sufficient identification is not provided along with the donation.
• Use of QR Codes is permitted, but it is important that QR Codes (or URL links) direct users to a dedicated page on the parish or school website where payment options are available.  Do not use QR Codes to direct users directly to Venmo, Zelle, etc.  It is easy for a wrongdoer to cover or change a QR Code with a different QR Code to misdirect funds to their personal account.
• Confirm receipt of donations promptly and issue a thank-you message to the donor.
• For donations received from Zelle:  Donor information such as a name and phone number or email address is generally associated with a Zelle account.  It is appropriate to contact the donor using this phone number or email address to obtain additional information needed to provide a receipt of the donation.
• For donations received through Venmo, a username of a donor may not sufficiently identify the donor.  Be sure to review memo information to help determine who the donor is. 
• If the identity of the donor cannot be determined, it is acceptable to treat the donation as an anonymous cash donation. However, best efforts should be made to determine donor identity of donations that exceed $250 so that a proper receipt may be provided.

• Log each donation in the parish, school, or other location's financial records, including donor details, amount, and date.
• Generate regular reports on donations received through Venmo and Zelle for review by the Pastor, principal, person in charge, business manager and finance council, as applicable.
• See Section 6.2.1.7 Individual Records and Acknowledgment of Charitable Contributions for the required information that must be included in a receipt to a donor.
  

• Peer to Peer payment services should not be the primary mechanism for collecting tuition but can be used in extenuating circumstances with approval by the person-in-charge, such as the Pastor or Principal.  An example of an extenuating circumstance is if someone needs to quickly pay a balance due in order to start a new school year or to graduate.       

• Protect donor information by adhering to privacy policies and using secure systems for transaction processing.
• Regularly update passwords and security settings for Venmo and Zelle accounts.
• Adhere to the Archdiocese of Los Angeles Acceptable Use Policy located in Chapter 10 of the Administrative Handbook.
  

• ​Provide clear disclosures to donors, including the identity of the entity receiving the donation, any fees deducted, tax deductibility, and the time frame for processing donations. 

11-05-2025, 11-10-2025​
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